Over the years the SEC’s Enforcement Division has brought a number of cases against companies, including J.P. Morgan Securities LLC, CBRE, Inc. and The Brink’s Company, for violating Rule 21F-17(a) of the Securities Exchange Act of 1934.
This section of the Act prohibits companies from taking any action to limit communicating directly with the SEC concerning a possible securities law violation.
In a sign that this kind of violation will continue to be a focus area for the Enforcement Division, this May 22, 2026, Administrative Proceeding Summary announced settled charges against Foot Locker, Inc. for using separation agreements that violated Rule 21F-17(a). The company entered into a cease and desist order and paid a $148,000 civil penalty.
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